What's Coming in 2027: Decoding CMS's Proposed Outpatient Payment Changes for Hospitals and ASCs

Presenter: Lynn M. Barrett, Esq., BCS, CHC, CCP

Date: Tuesday, November 17, 2026

Time: 3 pm ET | 2 pm CT | 1 pm MT | 12 pm PT

Duration: 60 minutes

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Course Description

CMS has proposed sweeping changes to hospital outpatient and ambulatory surgical center reimbursement for calendar year 2027. This webinar provides a practical walkthrough of the most consequential provisions in CMS-1850-P

In this webinar, our speaker, Lynn Barrett, will cover the proposed 2.4% OPPS and ASC payment update, CMS’s dramatic shift in 340B drug reimbursement, including a discussion of what 340B reimbursement may look like under a rebate model, and the second year of the Inpatient Only (IPO) list phase-out affecting 637 procedures. Participants will also learn about the proposed site-neutral imaging payment policy for off-campus provider-based departments, the expansion of mandatory prior authorization to Botox injections, and CMS’s new Software as a Medical Service (SaMS) framework for AI-enabled diagnostics.

Additional topics include the elimination of the breakthrough device pass-through pathway, proposed EMTALA accreditation organization deeming authority, and key updates to the Hospital OQR and ASC Quality Reporting programs.

Whether you work in or with hospitals, ASCs, or health systems, this webinar is designed to equip you to prepare for the proposed changes should they become final. You will be able to understand and/or advise your clients on compliance obligations and strategic planning before the final rule is promulgated, the majority of which would likely take effect on January 1, 2027.

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Learning Outcomes

• Explain the CY 2027 OPPS and ASC payment updates.
• Describe CMS’s proposed 340B reimbursement methodology.
• Discuss the proposed 340B rebate demonstration model.
• Identify Year 2 changes to the Inpatient Only list.
• Explain site-neutral imaging payment changes for off-campus PBDs.
• Describe CMS’s SaMS coding and payment framework.
• Explain the proposed EMTALA deeming authority changes.
• Review Hospital OQR and ASC QRP requirements and penalties.
• Explain the proposed elimination of breakthrough device pass-through.
• Identify key steps to prepare for CY 2027 changes.

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Areas Covered in the Session

• CY 2027 OPPS and ASC Payment Update
• 340B Drug Reimbursement Methodology
  • Proposed changes to Medicare reimbursement for 340B-acquired drugs
  • Key differences from the current payment methodology
  • Potential operational and financial implications for hospitals
  • Rebate demonstration model and possible future reimbursement approaches
  • Considerations for hospitals preparing for changes in 340B payments
• Year 2 Inpatient Only (IPO) List Phase-Out
• Site-Neutral Imaging Payment Policy for Off-Campus Provider-Based Departments
  • Proposed application of site-neutral payment principles to imaging services
  • Services and departments potentially affected
  • Reimbursement implications for hospital outpatient departments
  • Strategic considerations for health systems and provider-based entities
• Software as a Medical Service (SaMS) Coding and Payment Policy
• Mandatory Prior Authorization Expansion for Botox Injections
• EMTALA Accreditation Organization Deeming Authority
  • Proposed expansion of accreditation organization authority
  • Relationship between accreditation and EMTALA compliance oversight
  • Potential impact on hospitals and emergency departments
  • Compliance considerations for hospital leadership
  • Preparing for implementation if finalized
• Hospital Outpatient Quality Reporting (OQR) Program
• Ambulatory Surgical Center Quality Reporting (ASC QRP) Program
  • Key reporting requirements and proposed updates
  • Quality measure and reporting considerations
  • Payment reduction and penalty structure
  • Operational implications for ASCs
• Elimination of the Breakthrough Device Pass-Through Pathway
• Proposed Changes Affecting Hospital Outpatient Reimbursement
• CMS Payment, Coding, and Compliance Implications for 2027
  • How proposed payment policies may affect coding and billing operations
  • Interaction between reimbursement policy and compliance requirements
  • Financial planning considerations for hospitals and ASCs
  • Preparing internal teams for potential 2027 changes
  • Monitoring the rulemaking process before final implementation
• Strategic Planning for Hospitals, ASCs, and Health Systems
• Preparing for the Final CY 2027 OPPS/ASC Rule
  • Key differences between proposed and final rule requirements
  • Areas requiring early operational review
  • Potential January 1, 2027 implementation considerations
  • Internal education and stakeholder communication
  • Compliance preparation before finalization
• Financial, Operational, and Compliance Impact of the Proposed Rule
• Interactive Q&A Session with Lynn M. Barrett, Esq., BCS, CHC, CCP

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Recommended Participants

• Chief Financial Officers (CFOs)
• Hospital Comptrollers
• Revenue Cycle Directors and Managers
• Reimbursement Managers and Specialists
• Hospital Billing Managers and Supervisors
• Certified Professional Coders (CPCs)
• Certified Coding Specialists (CCS)
• Certified Inpatient Coders (CICs)
• Healthcare Compliance Officers
• Compliance Managers and Compliance Specialists
• Healthcare Attorneys and Legal Counsel
• Regulatory Affairs Professionals
• Health Information Management (HIM) Directors and Managers
• Clinical Documentation Integrity (CDI) Managers and Specialists
• Hospital Outpatient Services Directors and Managers
• Ambulatory Surgery Center (ASC) Administrators and Directors
• Revenue Integrity Directors and Managers
• Managed Care and Contracting Directors
• Quality Reporting and Quality Improvement Managers
• Healthcare Internal Audit and Regulatory Risk Professionals

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About the Presenter

With 35 years of experience, Lynn M. Barrett is a board-certified health law, regulatory, compliance, and transactional attorney with significant experience in matters involving federal and state healthcare laws and regulations, particularly those involving the Stark Law, the Anti-Kickback Statute, CMPs, and EKRA.

Prior to opening her own practice, Lynn served as General Counsel for one of the largest public health systems in the United States, where she worked collaboratively to implement a Corporate Integrity Agreement, with a particular focus on creating a robust compliance program. Previously, Lynn served as Senior Vice President and Chief Compliance and Ethics Officer for a large, multi-facility academic medical system, where she was also responsible for privacy and security.

Lynn has also served as a Partner and Associate at various large healthcare law firms, as well as in-house counsel for for-profit, nonprofit, and public health systems. In these positions, she has worked on a wide array of legal and compliance issues, including physician and referral source arrangements, HIPAA privacy and security matters, clinical research, transactional and operational matters, medical staff issues, medical necessity, quality of care, and Board governance.

In addition, Lynn has performed numerous compliance effectiveness reviews and has developed, reviewed, and updated compliance programs for numerous providers, including home health agencies, clinical laboratories, and physician practices. Lynn has served as an Independent Review Organization for entities under CIAs.

She has also served as an Adjunct Professor at several institutions, where she created and taught courses on healthcare compliance and taught courses on business arrangements, Medicare & Medicaid, and bioethics. She is certified in Compliance by the Health Care Compliance Association and has been designated as a Certified Compliance Professional by the Health Ethics Trust.

Lynn holds leadership positions in AHLA, NAWL, and the ABA, is a Fellow of the ABA, and is a member of the American College of Legal Medicine. Lynn received her J.D. degree from New York University School of Law in 1991 and her B.S. from Carnegie Mellon University in 1986.

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